14.3.1 [a] U.S Taxation of Canadian Residents on Personal Services IncomeUnder the Code, non-resident aliens who earn income in the U.S. are subject to federal income tax on the portion...
Posted by The Accounting and Tax on 01/21/2019
14.2.2[a] Independent Personal ServicesArticle XIV governs income earned by an individual from independent personal services. Any type of business or professional activity could qualify...
Posted by The Accounting and Tax on 01/21/2019
14.1 Introduction to Article XIV – Independent Personal ServicesArticle XIV deals with the provision of independent services in one Contracting State by an individual who is...
Posted by The Accounting and Tax on 12/06/2018
13.3.2 [a] Article XIII(1) – Gains from Real PropertyParagraph 1 authorizes the U.S. to tax gains derived by a resident of Canada from the alienation of real property situated...
Posted by The Accounting and Tax on 11/26/2018
13.3.1 [a] Taxation of Gains by Non-resident Aliens and Foreign CorporationsThe United States generally imposes a flat 30 percent tax, collected by withholding, on the gross amount...
Posted by The Accounting and Tax on 11/22/2018
13.2.2 [a] Article XIII(1) – Gains from Real PropertyArticle XIII(1) provides that the gains derived by a U.S. resident from the alienation of real property situated in Canada...
Posted by The Accounting and Tax on 10/30/2018
13.2.1 Canadian Taxation of Gains of Non-ResidentsCanada does not impose tax on gains from the disposition of property by a non-resident other than the disposition of taxable Canadian...
Posted by The Accounting and Tax on 10/22/2018
Article XIII generally deals with the taxation of capital gains realized by residents of Canada or the U.S. that may be also taxed in the other State. The general rule dealing...
Posted by The Accounting and Tax on 10/06/2018
12.3.2[a] Article XII(1) – Residence – Based Jurisdiction to TaxParagraph 1 of Article XII stands for the proposition that a resident of a country receiving royalty income...
Posted by The Accounting and Tax on 10/06/2018
